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Retail Accountability Wholesaler Frequently Asked Questions

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1. Why is this information report necessary?

The information report is required by T.C.A. §67-6-410, which was signed into law on April 4, 2012, by Governor Bill Haslam. Third-party information reporting has been shown to increase voluntary tax compliance, improve collections, and thereby reduce the tax gap.

2. When is the due date of the report?

The report is due monthly on the 25th of the month following the reporting period. For example, the January report would be due on February 25th. Please make sure that you do not cut off the month prematurely and upload end of month invoices at a later time. The upload deadline is 25 days after month end to ensure that all invoices dated within the reporting month can be included in the following calendar month report.

3. How will the report be used?

The Tennessee Department of Revenue will use the information reports to compare the sales made to the retailer with the retailer's sales made to the consumer as part of the department's tax audit program.

4. Is there tax due with the report?

No. But there are substantial penalties for not filing by the due date.

5. What are the penalties for filing late?

There is a $1,000 penalty for every month the report is not provided, or part thereof, up to a maximum of $10,000.

6. Is the data provided by the wholesaler/distributor confidential?

Yes. This data will be treated as confidential taxpayer information.

7. What format is the file?

The file format will be a csv comma delimited file. The file layout can be found by clicking this link:  Most software programs allow reports to be saved as a csv comma delimited file.

8. What if my data contains commas?

Commas in the customer name field, invoice amount field, or any other data field will cause errors in your information report.

9. May I include the field names on the first row of the data?

No, the information report should include only sales records. Do not include a header row or the field names in the data file at all.

10. How will the report be filed?

You will need to upload your electronic file to our website monthly.

11. How do I get a User ID and password in order to upload my monthly information report to the website portal?

You will need to setup a user ID and password for your organization to be able to upload your file.  At the Wholesaler Portal Login webpage you can create a new account under the Account Management area.  You will be able to create your own username and password.  The Wholesaler Portal Login webpage is at

12. The first field on the report asks for the wholesaler account number.  Which number is that?

This account number is different depending on if you are a beer wholesaler or a tobacco wholesaler.

Beer wholesalers use the 9 digit wholesaler beer account number that starts with 960.

Tennessee breweries use the 9 digit account number used when reporting the beer barrelage report.

Tobacco wholesalers or distributors use the 9 digit tobacco tax account number that starts with 860 and is used to file the TOB552 return.

13. I do not sell to retailers.  Do I still have to file a report?

Yes, for in state beer importers or breweries - Because Tennessee breweries can sell to retailers within their own county, they must file a report.  If they do not sell to retailers, they will file a zero (0) return monthly.

No, for out of state importers or breweries – Because the law requires you only to sell to wholesalers or distributors and you cannot sell directly to Tennessee retailers, you do not need to file a report.

Yes, for tobacco wholesalers and distributors – If you have a tobacco tax account with the state of Tennessee or regularly file the TOB552 return, you will be required to file a report.  If you do not have any sales to Tennessee retailers, you will still need to file a zero (0) return monthly.

14. One of the required data elements is the retailer’s sales tax account number.  How do I know if we have the correct number on file?  Can I leave it blank?

This is a required field since a retailer must provide a Blanket Certificate of Resale, which includes the sales tax account number, to the wholesaler/distributor in order to purchase products tax free to resell to their customers.  Each retailer is also required to post their sales tax certificate at their business location.  This certificate identifies the business name and sales tax account number. The sales account number is sometimes referred to as the Sales and Use tax number or resale certificate number.  Each retailer location has it’s own sales account number.  You can verify the validity of Sales and Use Resale and Exemption Certificates at

15. One of the data elements is the retailer’s beer permit number.  We do not sell beer.  Do we still need to get the customer’s beer permit number?

No.  If you do not sell beer products, then you do not need the retailer’s beer permit number and the field should be left blank.  However, if you are a beer wholesaler, you need to get the beer permit numbers for all your retail customers.

16. The partial NACS category list shows products other than beer and tobacco.  Are wholesalers supposed to report ALL sales on the report, including non-beer and non-tobacco sales?

The law only requires reporting of beer and tobacco sales.  However, since we are asking for information at the invoice level, wholesalers are encouraged to send in all sales that make up the invoice.  Please be sure there is a separate record (i.e. line) on the report for each NACS category for each invoice.  If all items are not included on the report, additional records will likely be requested during an audit or investigation.

17. One of the data elements is the retailer FEIN or social security number (SSN), and we do not have that information.  Do we need to get the retailer’s FEIN or SSN?

If you already have this information, please provide it.  You are not required to go out and obtain it from the retailers for the purpose of the monthly information report.  If you do not have the information, leave this field blank.

18. How do I record retailer credits or credit memos on the information report?

Credits on an invoice will be netted with other purchases on the same invoice within the same NACS category.  If the credit is more than purchases, the amount reported for NACS Category Total for Invoice will be a negative number.  The negative number should be formatted with a negative indicator before the number.  Example: -1234.56    Credit Memos should be included in the report as a negative invoice.

19. A retailer has informed me that I am reporting purchases on an old or closed sales tax number.  What actions should I take?

Please be advised that the Tennessee Department of Revenue - Blanket Certificate of Resale, clearly states that “The purchaser must notify the seller in writing if the certificate is no longer valid.” Therefore, the retailer should contact you in writing to notify you that their Blanket Certificate of Resale is no longer valid.  Once you are notified that an account number or a Sales and Use Tax Certificate of Resale is no longer valid, you are no longer permitted to make tax exempt sales for resale to that retailer.  If you continue to make any tax exempt sales to the retailer after you have been notified that the certificate is invalid, you will be held responsible for the tax on those sales.

20. I received an Invalid Sales Tax Account Alert email after uploading my monthly wholesaler report.  What does this mean?

During the validation process when uploading the monthly wholesaler report, we compare the Sales Tax account numbers in your report to our database of valid accounts.  If the account is not a valid number or has been closed at the time of upload, the account will be listed as invalid and you will receive the email alert.  The data you uploaded is accepted.  This alert is notification that you should not make any future sales to that account number.

Please be aware that once the Department or the retailer has notified you that an account number or a Sales and Use Tax Certificate of Resale is no longer valid, you are no longer permitted to make tax exempt sales for resale to that retailer.  If you continue to make any tax exempt sales to the retailer after you have been notified that the certificate is invalid, you will be held responsible for the tax on those sales.

21. What if a retailer has multiple locations and has product delivered to one central location?

All retail locations have separate Sales & Use Tax account numbers and Sales and Use Tax Certificates of Resale.  Therefore, your monthly information report must have the sales to each location clearly identified by location with the correct Sales & Use Tax account number.  Our recommendation would be separate invoices for each location with the appropriate customer name, location address, Sales & Use Tax account number, etc. with the ship to address indicating where the product was delivered.  This allows the customer information and Sales & Use Tax account number to be correct, but the taxpayers can receive the product at the desired location.  The monthly information report cannot use one Sales & Use Tax account number for multiple locations.

22. I have a resale certificate for a customer but I am not sure if they are a retailer or a distributor?

Include the sales to the customer on your report.  It is better to include too much information than not enough.  Once we get the information, we can determine if the customer is a retailer or distributor.

23. How does this benefit my company?

Currently during an audit or investigation of a retailer, the department requests or summons records that contain the same data required on this report.  Because the requests are done on an individual case by case basis, a wholesaler or distributor spends time and resources complying with the multiple requests.  We anticipate this report reducing or eliminating the request for records in the future.

24. What if I have read all of these questions and I still need help?

Please check our website for other reference materials that may answer your questions.  You can email additional questions to or call (615) 741-9300 within Nashville or (855) 286-7423 outside Nashville.